Rodriguez v. United States

Facts of the Case

Officer Struble, a K-9 officer, stopped petitioner Dennys Rodriguez for driving on a highway shoulder, a violation of Nebraska law. After Struble attended to everything relating to the stop, including checking the driver’s licenses of Rodriguez and his passenger and issuing a warning for the traffic offense, he asked Rodriguez for permission to walk his dog around the vehicle. When Rodriguez refused, Struble detained him until a second officer arrived. Struble then retrieved his dog, who alerted to the presence of drugs in the vehicle. The ensuing search revealed methamphetamine. Seven or eight minutes elapsed from the time Struble issued the written warning until the dog alerted. Rodriguez was indicted on federal drug charges. At trial in federal district court he moved to suppress the evidence seized from the vehicle on the ground, among others, that Struble had prolonged the traffic stop without reasonable suspicion in order to conduct the dog sniff. The magistrate judge recommended denial of the motion. He found no reasonable suspicion supporting detention once Struble issued the written warning. Under Eighth Circuit precedent, however, he concluded that prolonging the stop by seven to eight minutes for the dog sniff was only a

Question

Is the use of a K-9 unit, after the conclusion of a traffic stop and without reasonable suspicion of criminal activity, a violation of the Fourth Amendment prohibition on unreasonable search and seizures?

CONCLUSION

Yes. Justice Ruth Bader Ginsburg delivered the opinion for the 6-3 majority. The Court held that the use of a K-9 unit after the completion of an otherwise lawful traffic stop exceeded the time reasonably required to handle the matter and therefore violated the Fourth Amendment’s prohibition against unreasonable searches and seizures. Because the mission of the stop determines its allowable duration, the authority for the stop ends when the mission has been accomplished. The Court held that a seizure unrelated to the reason for the stop is lawful only so long as it does not measurably extend the stop’s duration. Although the use of a K-9 unit may cause only a small extension of the stop, it is not fairly characterized as connected to the mission of an ordinary traffic stop and is therefore unlawful.Justice Clarence Thomas wrote a dissent in which he argued that the use of a K-9 unit at the conclusion of an otherwise lawful traffic stop did not violate the Fourth Amendment as long as it was conducted reasonably, which this one was. Justice Thomas also argued that the rule announced in the majority’s opinion would result in arbitrary enforcement of Fourth Amendment protections and created artificial lines between common police practices at traffic stops. Additionally, there was no Fourth Amendment violation in this case because the police officer had a reasonable suspicion to continue to hold Rodriguez and use the K-9 unit. Justice Samuel A. Alito, Jr., and Justice Anthony M. Kennedy joined in the dissent. In his separate dissent, Justice Kennedy noted that the appellate court did not address the issue of whether the officer had a reasonable suspicion to use the K-9 unit, and that court should be allowed to do so. Justice Alito also wrote a separate dissent in which he argued that the majority opinion’s analysis was arbitrary because it relied on the order in which the officer conducted his inquiries.

Case Information

  • Citation: 575 US _ (2015)
  • Granted: Dec 2, 2014
  • Argued: Jan 21, 2015
  • Decided Apr 21, 2015